Outbound marketing (OBM) is the most-scrutinised area under CPNI enforcement. Section 64.2009(b) + (c) requirements: (a) MARKETING CAMPAIGN RECORDS - the carrier must maintain a record of its OUTBOUND sales + marketing campaigns that use the customer's CPNI for a minimum of 1 year. The record must include: (i) a DESCRIPTION OF EACH CAMPAIGN; (ii) the SPECIFIC CPNI that was used; (iii) WHAT PRODUCTS + SERVICES WERE OFFERED as part of the campaign. (b) SUPERVISORY REVIEW - sales personnel must OBTAIN SUPERVISORY APPROVAL OF ANY PROPOSED OUTBOUND MARKETING REQUEST FOR CUSTOMER APPROVAL. (c) ANNUAL OFFICER CERTIFICATION must specifically address OBM compliance + summarise OBM compliance. The 2007 + 2009 CPNI Orders identified OBM as a major risk-area following enforcement findings against several carriers for misleading OBM scripts + insufficient supervisory oversight.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.